Modern Slavery Policy Statement – Contechs Group Holdings Limited (“Contechs”)
This statement is made as part of Contechs’ commitment to eliminating the exploitation of people under the Modern Slavery Act 2015 (the Act). It summarises how Contechs operates, including active policies and processes which minimise the possibility of problems or risks the company has identified, how they are monitored and how company employees are trained.
This statement is published in accordance with Section 54 of the Act and relates to the financial year ending on 31st December 2022.
Signed By:
Peter Jarvis
Group Chief Operating Officer
Date: 13/02/2023
1. Background
1.1. Modern Slavery is a crime and a violation of human rights. We as a business are committed to the prevention of modern slavery within our supply chain and our business.
1.2. Contechs has a zero-tolerance policy in respect of modern slavery and promotes honesty, integrity and ethical practices within its business. Contechs is fully committed to implementing change and enforcing practices to prevent, avoid and combat modern slavery within its supply chains.
2. Our Business and its Structure
2.1. Contechs was founded in 1997, initially focusing on supply of engineering services to automotive companies.
2.2. Contechs has eight subsidiary companies in the UK, Germany and US which undertake a variety of services including:
2.2.1. Provision of engineering services
2.2.2. Recruitment services
2.2.3. Manufacturing
2.2.4. Materials handling
2.2.5. Contechs has a global turnover of £55m per year.
3. Our Suppliers
3.1. Due to the range of services Contechs offers, it works with suppliers across Europe in the supply of goods and across the globe in the supply of services. All individuals undertaking services on our behalf are known to Contechs and its staff. Contechs undertakes due diligence in relation to all service suppliers before they are approved to undertake services on behalf of Contechs.
3.2. Contechs maintains a membership of the Recruitment and Employment Confederation which seeks to ensure that recruitment companies incorporate ethical and fair practices within their recruitment procedures.
4. Our Policies
4.1. Contechs have a number of policies which incorporate its ethical practices which includes:
HR-P-0007 Anti-Bribery and Corruption Policy
HR-P-0014 Data Protection & General Data Protection Regulation
HR-P-0022 Ethics Policy
HR-P-0059 Whistleblowing Policy
QQ-P-0008 Corporate Social Responsibility Policy
QQ-P-0011 Labour Standards Policy Statement
4.2. Contechs requires its suppliers to adhere to the policies outlined above.
4.3. Contechs’ ethical trading policies are reviewed on a regular basis by internal and external legal and HR advisors and policy improvements are reviewed and approved at board level. Reported actual/suspected breaches of policy are reported to Senior Management or Company Director in-line with company policy.
4.4. Employees are encouraged to raise concerns in confidence with Senior Management.
5. Risk Assessments
5.1. Suppliers must complete a self-assessment due diligence questionnaire prior to being approved to provide services to Contechs. Individuals undertaking services for Contechs are known to the business, and communicate directly with Contechs.
5.2. In addition, where services are provided from countries considered high-risk with regard to modern slavery, Global Slavery Index e.g. India, Contechs undertakes supplier audits, usually on an annual basis.
5.3. Suppliers of goods are generally sourced from Western European countries, considered low-risk, and therefore minimal auditing is undertaken. Company processes are reviewed on a regular basis to ensure they continue to support the company regarding modern slavery requirements.
5.4. If the company decides to source products outside of Western Europe it will undertake more detailed assessment of these suppliers. To date, all suppliers to Contechs have been able to provide evidence of ethical practices within their organisations.
6. Training
6.1. Contechs understands the importance of ongoing training and ensures employees are trained annually to recognise and understand modern slavery, human trafficking, and how and when to report such practices.
7. Contact Details
Questions and comments regarding this statement are welcomed and should be addressed to hhunter@contechs.co.uk.